Legislation Enacted to Mitigate Overkill in Dutch Disregarded Permanent Establishment Rule Implementing ATAD 2

Journal
Bane, R.K.; Kleimann, R.
Netherlands
European Taxation 2025 (Volume 65), No. 2/3
Price USD 45

In this note, the authors comment on legislation recently enacted to neutralize overkill in the Dutch implementation of the hybrid mismatch rules contained in ATAD 2, which was drafted following an article published in a Dutch tax journal by the authors in 2023.